Quick answer: the transitional regime that let crypto-asset service providers (CASPs) operate in Spain without MiCA authorisation ended on 1 July 2026. Providers registered with the Banco de España as of 30 December 2024 could keep offering their services until that date, or until their authorisation was granted or refused if that came first; since then, only providers authorised by the CNMV, or passported in from another European authority, may operate (MiCA, Regulation (EU) 2023/1114, Art. 143(3)). According to ESMA (statement of 23 June 2026), CASPs that were not authorised must stop onboarding clients and advertising, and limit themselves to closing positions or transferring their clients' assets in an orderly way.
What ended on 1 July 2026
MiCA has applied in full to crypto-asset service providers since 30 December 2024. Spain did not shorten the transitional period and applied the maximum of 18 months, so firms already operating remained covered until 1 July 2026 without needing the new authorisation. Since that date, providing crypto-asset services without the CNMV's CASP authorisation, or without a European passport, is not permitted. The CNMV has already published its authorisation criteria in a questions-and-answers document (December 2025).
Who it affects, and who it does not
The deadline affects CASPs: exchange platforms, crypto-asset custodians and services for the execution, advice on, or portfolio management of crypto-assets. These services fall within MiCA because they relate to crypto-assets that are not financial instruments.
It does not affect security tokens. A tokenised security (a share, a bond, a fund unit) is a financial instrument and sits outside MiCA (Regulation (EU) 2023/1114, Art. 2(4)): it falls under MiFID II (Directive 2014/65/EU) and, in Spain, under Ley 6/2023 (Spain's Securities Markets Law, LMVSI), and its on-chain registration runs through an ERIR (the entity responsible for the registration and recording of DLT-based securities). Confusing the two regimes is the costliest mistake in this field.
What to do if you are a CASP
- Check whether the firm is listed as an authorised CASP in the ESMA or CNMV register: transitional cover ended on 1 July 2026.
- If authorisation was not obtained in time, stop onboarding and advertising and organise an orderly exit for clients, as ESMA requires; the way back is to apply to the CNMV for CASP authorisation, which is not immediate.
- Review capital, governance, custody and conflict-of-interest requirements, along with the CNMV guidance (December 2025 questions and answers).
- If the model touches tokenised financial instruments, ring-fence that part clearly: it falls under MiFID II and the LMVSI, not under the CASP authorisation.
MiCA timeline
- 30 June 2024: the rules for e-money tokens (EMTs) and asset-referenced tokens (ARTs) apply, Titles III and IV.
- 30 December 2024: application of the rest of the Regulation (Art. 149(2)), including Titles II (other crypto-assets), V (CASPs) and VI (market abuse).
- 1 July 2026: the Spanish transitional regime for CASPs ends. From this date, only authorised providers operate.
What this means for you
If you provide crypto-asset services without MiCA authorisation, the transitional period is over: you cannot onboard clients or advertise in Spain until you obtain it. If your project is about issuing tokenised securities, the MiCA calendar is not your calendar; your framework is MiFID II, the LMVSI and the appointment of an ERIR.
If you are comparing jurisdictions, the number of authorised CASPs, the transitional period and the supervisor of each Member State are in MiCA license by country.
Frequently asked questions
When exactly did the transitional regime end in Spain?
It ended on 1 July 2026. Until that date, providers registered with the Banco de España as of 30 December 2024 could keep operating.
Does the MiCA deadline affect security tokens?
No. Security tokens are financial instruments, excluded from MiCA (Art. 2(4)) and governed by MiFID II and the LMVSI.
What happens if I did not obtain the CASP authorisation in time?
Since 1 July 2026 you cannot provide crypto-asset services in Spain without CNMV authorisation or a European passport; ESMA expects unauthorised providers to stop onboarding clients and wind down their activity in an orderly way.
This content is for general information and educational purposes only. It is not legal, tax or investment advice and does not replace consultation with a qualified professional. Regulation on tokenisation and crypto-assets evolves; always check the version in force of the rules cited in the BOE (boe.es) and EUR-Lex (eur-lex.europa.eu).
Does your company provide crypto-asset services or plan to issue a token, and need to know which framework applies? At Unknown Gravity we classify your token and guide you through the framework that applies. Book a meeting.